Epstein Secrets

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN MATTER OF APPLICATION OF BRADLEY JAMES EDWARDS SEEKING CPLR 3102(E) ORDER FOR DAILY NEWS, L.P. TO PRODUCE TAPE RECORDING Index No. 112345/10 REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF MOTI

stein has ulterior motives and purposes in exercising such illegal, improper, and perverted use of process. His real purpose was to put pressure on Edwards„ and other victims by publishing what amounts to nothing more than a press release issued under the cloak of protection of the litigation privilege."

gation about that very subject in Florida. Movant Bradley J. Edwards is involved in a hotly contested lawsuit, in whi

dmission Pending) (: " 4—'4 ;telte) 332 S. 1400 E. Salt Lake City UT 84112 Telephone: Facsimile: E-Mail: cassel 1 DOlaw. utah.ed u Counsel for Bradley James Edwards 13 EFTA00729050 AFFIRMATION OF SERVICE As agreed in advance with counsel for the Daily News, I HEREBY AFFIRM that on November 11, 2010, I cause

00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co., 178P.Id 1176, 1183 (Ariz. App. 2008) Ulrich v. Coast Dental Services. In

istrict of Florida, D.C. Docket No. 9:08-cv-80736-KAM Attorneys and Law Firms Paul Cassell, University of Utah College of Law, SALT LAKE CTY, UT, Bradley James Edwards, Edwards Pottinger, LLC, FORT LAUDERDALE, FL, for Petitioner. Richard Christian Komando, Bradley Garrison & Komando, ORANGE PARK, FL, for Amicus C

ted. During that meeting, however, the federal prosecutors and FBI agents still did not disclose the Agreement to Wild. Then, in mid-June of 2008, Bradley Edwards, the attorney for Wild and several of Epstein's other victims, discussed with AUSA Villafafia the possibility of federal charges being filed agains

18 months' imprisonment in the county jail. Having still not been informed of the resolution of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office communicating the victims' wishes that federal charges be filed against Epstein. II. PROCEDURAL HISTOR

tion of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office comm

e-charge model does not raise 'serious constitutional problems," there is no issue. Edward J. DeBartolo Corp. v. Florida Gulf Coast Bldg. & Constr. Trades Council. 485 U.S. 568. 575. 108 S. Ct. 1392. 1397. 99 L.Ed.2d 645 (1988)). But I do not believe the text is so clear, and—as I discuss below—I believe the

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

HERE ARE NO MATERIAL FACTS IN DISPUTE 17 CONCLUSION 18 ii EFTA00728010 TABLE OF AUTHORITIES CASES Altemosc Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) 19 Apicella v. McNeil Labs. Inc. 66 F.R.D. 78 (E.D.N.Y. 1975) 4 Mel v. Murphy, 70 F.R.D. 651 (D.R.I. 1976) 5

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

HERE ARE NO MATERIAL FACTS IN DISPUTE 17 CONCLUSION 18 ii EFTA00207333 TABLE OF AUTHORITIES CASES Altemosc Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) 19 Apicella v. McNeil Labs. Inc. 66 F.R.D. 78 (E.D.N.Y. 1975) 4 Mel v. Murphy, 70 F.R.D. 651 (D.R.I. 1976) 5